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German Import Tax: Sanctions and Trade Restrictions

EU Regulation Deep-Dives 8 min read
German Import Tax: Sanctions and Trade Restrictions

Quick answer

German import tax compliance requires EU businesses to navigate not only customs duties but also sanctions and trade restrictions imposed by the EU. Compliance involves understanding which entities and individuals are subject to sanctions, the impact on trade flows, and the specific obligations for importers and exporters within the EU single market.

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Key takeaways

  • Sanctions target specific entities and individuals, including companies in Russia and China linked to military or destabilising activities in Ukraine [1][2][3][4].
  • German businesses importing goods must ensure they do not engage with sanctioned entities to avoid breaching EU restrictive measures [1:1][2:1].
  • Obligations include screening counterparties, declaring goods accurately with the correct commodity codes, and cooperating with customs authorities in the relevant Member State [5].
  • Non-compliance with sanctions and trade restrictions can lead to severe penalties and reputational damage [1:2][6].
  • The broader EU trade policy context integrates sanctions into customs and tax regimes, affecting tariffs and import tax calculations [5:1].
  • Specific cases involving Russian and Chinese companies illustrate the practical application of sanctions in the German import tax context [1:3][2:2][7][6:1].

Identifying Sanctioned Entities and Individuals

EU sanctions impose restrictive measures on entities and individuals considered to undermine or threaten the territorial integrity, sovereignty, and independence of Ukraine. These sanctions are legally binding across all EU Member States, including Germany, as per Council Decisions and Implementing Regulations.

For example, Shandong ODES Industry Co. Ltd., a Chinese limited liability company manufacturing all-terrain vehicles, is sanctioned for supplying the Russian Armed Forces, thus supporting military operations in Ukraine [1:4][2:3]. Similarly, LLC “Ulyanovsk Machine Tool Plant,” a Russian company producing CNC machine tools critical to Russia’s military-industrial complex, is subject to asset seizure and control transfer by the Russian government without the consent of previous German owners [1:5][2:4].

Individuals such as Sergey Dyachkov, a co-controlling shareholder of the Volga Dnepr Group, and Viktor Rashnikov, owner of Magnitogorsk Iron & Steel Works, are also sanctioned for materially supporting the Russian government’s actions in Ukraine [3:1][4:1][7:1][6:2]. These sanctions encompass asset freezes, trade restrictions, and prohibitions on providing funds or economic resources.

German businesses must maintain up-to-date sanction lists published by the EU and verify the status of trading partners, including beneficial owners and controlling shareholders, to ensure compliance.

Impact of Sanctions on German Businesses

Sanctions affect German businesses involved in importing goods, especially where the goods originate from or are linked to sanctioned entities. The presence of sanctions can lead to the prohibition of imports or exports, suspension of licences, or additional customs scrutiny.

For instance, German companies previously owning or controlling Russian entities now under Russian government control may face restrictions on dealings with such entities [1:6][2:5]. Moreover, goods linked to military use or dual-use technology may be subject to export controls or import bans under EU restrictive measures.

The german import tax regime must be applied in conjunction with these sanctions. This means that even if customs duties or import taxes are due, the import may be prohibited or require special authorisation if the goods or counterparties are sanctioned.

Businesses must also consider that sanctions can impact the supply chain, requiring alternative sourcing or adjustments in pricing due to potential tariffs or additional compliance costs.

Obligations for EU Importers and Exporters

EU importers and exporters operating in Germany must comply with both customs and sanctions regulations. Key obligations include:

  • Screening counterparties: Verifying that customers, suppliers, and associated entities are not listed on EU sanctions lists [1:7][2:6].
  • Customs declarations: Accurately declaring goods with the correct commodity codes and customs value, which is essential for calculating the german import tax and any applicable duties [5:2].
  • Licensing and authorisations: Obtaining necessary licences for goods subject to export controls or sanctions.
  • Cooperation with authorities: Providing documentation and information upon request by the customs authorities of the relevant Member State.
  • Record keeping: Maintaining records of transactions and due diligence efforts to demonstrate compliance.

The german import tax is calculated based on the customs value declared in the customs declaration. Importers must ensure that no sanctions-related restrictions affect the transaction or the goods, as this can invalidate the declaration or lead to penalties.

Due Diligence and Compliance Best Practices

To stay compliant with german import tax rules and EU sanctions, businesses should implement robust due diligence and compliance programmes:

  • Regularly update sanction screening tools: Use the latest EU sanctions lists and integrate them into procurement and sales processes.
  • Train staff: Ensure that employees responsible for customs declarations and trade compliance understand sanctions and import tax obligations.
  • Conduct risk assessments: Identify high-risk countries, sectors, and counterparties linked to sanctioned activities.
  • Engage with customs authorities: Clarify any uncertainties regarding classification, valuation, or sanctions compliance with the relevant national competent authority.
  • Document compliance efforts: Keep detailed records of screening results, licences obtained, and communications with authorities.

These measures help mitigate risks of inadvertent breaches of sanctions or customs regulations, which can lead to financial penalties or reputational harm.

Consequences of Non-Compliance

Failure to comply with german import tax obligations and EU sanctions can result in:

  • Financial penalties: Fines imposed by customs or other enforcement bodies.
  • Seizure or confiscation of goods: Customs authorities may detain or confiscate goods linked to sanctioned entities or undeclared import tax.
  • Criminal liability: In serious cases, breaches may lead to criminal prosecution.
  • Reputational damage: Loss of business trust and market access.
  • Suspension of licences: Export or import authorisations may be revoked.

Given these risks, businesses must prioritise compliance and seek clarification from the relevant national competent authority when in doubt.

Specific Cases: Russian and Chinese Entities

Recent EU sanctions highlight specific Russian and Chinese companies relevant to german import tax compliance:

  • Shandong ODES Industry Co. Ltd. (China): Sanctioned for supplying all-terrain vehicles to the Russian military, supporting the war effort in Ukraine [1:8][2:7].
  • LLC “Ulyanovsk Machine Tool Plant” (Russia): Previously owned by German companies, now under Russian government control following asset seizure, involved in military production [1:9][2:8].
  • Volga Dnepr Group (Russia): Controlled partly by Sergey Dyachkov, providing air cargo services critical to the Russian military-industrial complex, subject to sanctions [3:2][4:2].
  • Magnitogorsk Iron & Steel Works (Russia): Owned by Viktor Rashnikov, a major taxpayer supporting the Russian government, sanctioned for its role in financing the war [7:2][6:3].
  • Alfa Group and associated persons: Alexey Kuzmichev and related entities involved in sectors supporting Russian military and government activities, subject to restrictive measures [7:3][6:4].

German importers must avoid transactions involving these entities or their controlled subsidiaries, and ensure their supply chains are free from sanctioned parties.

Broader EU Trade Policy Context

The german import tax system operates within the broader framework of EU trade policy, which integrates customs duties, anti-dumping measures, and sanctions enforcement.

For example, the EU imposes countervailing duties and anti-dumping tariffs on imports from certain countries, including China, to protect the Union market [5:3]. These measures affect the calculation of import taxes and duties payable by German importers.

Sanctions add another layer of complexity, requiring that customs declarations reflect compliance with restrictive measures. The EU’s unified customs code and the use of EORI numbers facilitate customs control and enforcement across Member States, including Germany.

Businesses must therefore consider all applicable EU trade rules—tariffs, anti-dumping duties, and sanctions—when calculating the german import tax and planning cross-border transactions.

Next steps

  1. Verify the sanction status of all trading partners and counterparties against the latest EU sanctions lists to avoid prohibited transactions.
  2. Confirm the correct commodity codes and customs values for all imported goods to ensure accurate german import tax declarations.
  3. Obtain any necessary licences or authorisations for goods subject to export controls or sanctions before import.
  4. Maintain comprehensive records of due diligence, customs declarations, and communications with the relevant national competent authority.
  5. Regularly review compliance procedures and update staff training to reflect changes in EU sanctions and customs regulations.

FAQ

Do I have to pay import tax from Germany to the UK?
Import tax obligations depend on the customs rules applicable between the EU and the UK. Since the UK is no longer in the EU single market, imports from Germany to the UK generally require customs declarations and payment of import duties or VAT as per UK regulations. This is outside the german import tax regime within the EU [5:4].

How much is the tariff on German imports?
Tariffs on imports into Germany vary depending on the product’s commodity code, origin, and applicable trade measures such as anti-dumping duties. The EU Common Customs Tariff applies uniformly across Member States, including Germany. Specific tariffs must be checked per product classification [5:5].

Is import tax 20%?
The 20% figure often refers to the standard VAT rate in Germany applied on imports, not the import duty itself. Import duties vary by product and origin. Import VAT is calculated on the customs value plus any applicable duty and other costs [5:6].

What are the new EU customs rules for 2026?
As of 26 September 2026, the EU customs rules continue to require accurate customs declarations, use of EORI numbers, and compliance with sanctions and trade restrictions. Specific amendments or updates may have been made, so businesses should verify the current consolidated text on EUR-Lex or consult the relevant national competent authority [5:7].

Sources


  1. Council Decision (CFSP) 2025/1478 of 18 July 2025 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, Article 2

  2. Council Implementing Regulation (EU) 2025/1476 of 18 July 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, Article 2

  3. Council Decision (CFSP) 2024/1738 of 24 June 2024 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, Article 2

  4. Council Implementing Regulation (EU) 2024/1746 of 24 June 2024 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, Article 2

  5. Commission Implementing Regulation (EU) 2017/366 of 1 March 2017 imposing definitive countervailing duties on imports of crystalline silicon photovoltaic modules and key components (i.e. cells) originating in or consigned from the People’s Republic of China following an expiry review pursuant to Article 18(2) of Regulation (EU) 2016/1037 of the European Parliament and of the Council and terminating the partial interim review investigation pursuant to Article 19(3) of Regulation (EU) 2016/1037, Article 95

  6. Council Implementing Regulation (EU) 2025/527 of 14 March 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

  7. Council Decision (CFSP) 2025/528 of 14 March 2025 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, Article 2

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